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Abhijit Kumar Singh Vs The State of Bihar — Patna HC (2025) — LawSathi Research

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Patna HC
2025
Abhijit Kumar Singh Vs The State of BiharAbhijit Kumar Singh v. The State of Bihar

Allowed¶21

Abhijit Kumar Singh v. The State of Bihar

Anticipatory bail – concealment/non-disclosure of criminal antecedents

Patna HC5 Dec 2025CR. MISC./6702/2025

Case brief

AI extract

What is this about?

Cancellation of anticipatory bail for concealment of criminal antecedents; Patna High Court; Satyavrat Verma, J.; oral order dated 05-12-2025; Cr. Misc. No.6702 of 2025 arising out of P.S. Case No.388/2021, Bettiah City, West Champaran; petitioner Abhijit Kumar Singh (counsels Anuj Kumar and Senior counsel Anshul); O.P. No.2 Abhishek Rai @ Abhishek Kumar Rai (Senior counsel Ramakant Sharma); earlier order dated 15.09.2022 in Cr. Misc. No.13257 of 2022 granting anticipatory bail cancelled; five antecedents disclosed at Para-3 against larger antecedent count (fourteen cases/four acquittals and ten-case figures cited); submissions unrebutted; precedent that accused may conceal antecedents to obtain anticipatory bail.

What did the court decide?

Cancellation of the anticipatory bail granted to O.P. No.2 (Abhishek Rai) by order dated 15.09.2022 in Cr. Misc. No.13257 of 2022.

Why is it important?

As the learned Senior counsel for O.P. No.2 was not in a position to rebut the submissions of the petitioner's counsel regarding non-disclosure of antecedents, the order dated 15.09.2022 in Cr. Misc. No.13257 of 2022 granting anticipatory bail to O.P. No.2 is cancelled. ¶21

What the court decided

AI extract

Outcome

Cancellation of the anticipatory bail granted to O.P. No.2 (Abhishek Rai) by order dated 15.09.2022 in Cr. Misc. No.13257 of 2022.

Issue for consideration

Whether the anticipatory bail privilege granted to O.P. No.2 (Abhishek Rai) by the order dated 15.09.2022 in Cr. Misc. No.13257 of 2022 should be cancelled on account of non-disclosure/concealment of his criminal antecedents.

Ratio / Principle

As the learned Senior counsel for O.P. No.2 was not in a position to rebut the submissions of the petitioner's counsel regarding non-disclosure of antecedents, the order dated 15.09.2022 in Cr. Misc. No.13257 of 2022 granting anticipatory bail to O.P. No.2 is cancelled.

Detailed headnote1 paragraphs

Anticipatory bail - concealment/non-disclosure of criminal antecedents - cancellation of bail order. By oral order dated 05-12-2025 in Cr. Misc. No.6702 of 2025 (arising out of P.S. Case No.388 of 2021, Bettiah City P.S., West Champaran), Satyavrat Verma, J. of the Patna High Court cancelled the anticipatory bail granted to O.P. No.2 Abhishek Rai @ Abhishek Kumar Rai by order dated 15.09.2022 in Cr. Misc. No.13257 of 2022. The petitioner submitted that O.P. No.2 had disclosed only five antecedents at Para-3 of his 2022 anticipatory bail application despite having further antecedents (counsel cited fourteen cases with four acquittals, and separately ten antecedents on the filing date), that O.P. No.2 was aware of his antecedents, and that allowing the privilege to continue would set a precedent encouraging accused persons to conceal antecedents to obtain anticipatory bail. Counsel for O.P. No.2 was unable to rebut the submissions; the Court accordingly cancelled the privilege of anticipatory bail.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.6702 of 2025

Arising Out of PS. Case No.-388 Year-2021 Thana- BETTIAH CITY District- West

Champaran

======================================================

Abhijit Kumar Singh S/o Jitendra Singh R/o Ward No- 2 Paras Pakri, Chanainbandh, P.S- Gojholiya, Dist- West Champaran

... ... Petitioner/s

Versus

The State of Bihar

Abhishek Rai @ Abhishek Kumar Rai S/o Late Ashok Rai R/o Siswa Bhumihar, P.S. - Nawalpur, Distt.- West Champaran, At present R/o Bettiah Station Chowk, P.S. - Bettiah Town, Distt.- West Champaran

... ... Opposite Party/s

======================================================

Appearance :

For the Petitioner/s : Mr. Anuj Kumar For the Opposite Party/s : Mr. Dr. Kumar Uday Pratap ======================================================

CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

8 05-12-2025

Heard learned Senior counsel for the petitioner Mr.

Anshul, learned A.P.P. for the State and the learned Senior counsel appearing on behalf of the O.P. No.2 Mr. Ramakant Sharma.

The learned Senior counsel appearing on behalf of the petitioner submits that O.P. No.2 had moved before this Court seeking anticipatory bail by filing Cr. Misc. No.13257 of 2022 and the same was allowed by an order dated 15.09.2022. It is submitted that O.P. No.2 in Cr. Misc. No.13257 of 2022 had disclosed 5 antecedents when he had antecedent of 14 cases but then was acquitted in four cases as such five cases more remained. It is submitted that on the date when Cr. Misc.

Patna High Court CR. MISC. No.6702 of 2025(8) dt.05-12-2025 2/2

No.13257 of 2022 was filed, on that date, petitioner was having antecedent of 10 cases but then at Para-3, only five antecedents were mentioned. It is next submitted that had 10 antecedents been mentioned, perhaps the consideration of the court would have been different. It is next submitted that it is not the case of the O.P. No.2 that he was not aware that he has antecedent of 14 cases, in which, he was acquitted in four cases. It is also submitted that if the privilege of anticipatory bail granted to the petitioner is allowed to continue, in that event, it will set a precedent that any accused can come concealing his antecedent and after obtaining anticipatory bail will accept his mistake.

The learned Senior counsel appearing on behalf of the O.P. No.2 is not in a position to rebut the submissions of the learned Senior counsel appearing on behalf of the petitioner, as such, the order dated 15.09.2022 in Cr. Misc. No.13257 of 2022, by which, O.P. No.2 was granted the privilege of anticipatory bail is hereby cancelled .

(Satyavrat Verma, J)

amit/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the anticipatory bail privilege granted to O.P. No.2 (Abhishek Rai) by the order dated 15.09.2022 in Cr. Misc. No.13257 of 2022 should be cancelled on account of non-disclosure/concealment of his criminal antecedents.medium confidence¶20

Procedural history

How this case reached the court

AI extract

Order under challenge
Grant of anticipatory bail to O.P. No.2 (Abhishek Rai) by order dated 15.09.2022 in Cr. Misc. No.13257 of 2022¶18
This Court (Patna High Court) · 15.09.2022
Prior proceeding
O.P. No.2 filed Cr. Misc. No.13257 of 2022 before this Court seeking anticipatory bail; the application was allowed by order dated 15.09.2022¶18
Prior proceeding
Submission by petitioner's counsel that in Cr. Misc. No.13257 of 2022 O.P. No.2 disclosed only five antecedents while, per counsel, he had antecedent of 14 cases and had been acquitted in four of them¶18
Prior proceeding
Further submission that on the date of filing of Cr. Misc. No.13257 of 2022 ten antecedents existed but only five were mentioned at Para-3 (the submission attributes the figure to 'petitioner')¶20

Parties & counsel

AI extract

petitioner
Abhijit Kumar Singh¶5
Anuj Kumar, Anshul (Sr.)
respondent
The State of Bihar¶8
respondent
Abhishek Rai @ Abhishek Kumar Rai¶9
Ramakant Sharma (Sr.)

Coram

AI extract

Satyavrat Vermaauthor¶14

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 5 Dec 2025 · December
Registered: 29 Jan 2025
Case no.: CR. MISC./6702/2025
CNR: BRHC010066342025
Bench: Satyavrat Verma
Disposal: ALLOWED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Abhijit Kumar Singh v. The State of Bihar, CR. MISC./6702/2025 (PAT), decided on 5 December 2025.

The Patna High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Procedural history4

Grant of anticipatory bail to O.P. No.2 (Abhishek Rai) by order dated 15.09.2022 in Cr. Misc. No.13257 of 2022This Court (Patna High Court) · 15.09.2022
O.P. No.2 filed Cr. Misc. No.13257 of 2022 before this Court seeking anticipatory bail; the application was allowed by order dated 15.09.2022
Submission by petitioner's counsel that in Cr. Misc. No.13257 of 2022 O.P. No.2 disclosed only five antecedents while, per counsel, he had antecedent of 14 cases and had been acquitted in four of them

View full history

Bench / Coram

Satyavrat Verma

Parties & counsel